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Job Location & CHAPTER

6
Development

The Job Location and Development (JLD) Program is one of the JLD Purpose Cites
FWS Programs. An institution is allowed to use part of the federal 34 CFR 675.31
funds it receives under the FWS Program to establish or expand a JLD
Program.

The JLD Program locates and develops off-campus job


opportunities for students who are currently enrolled in eligible
institutions of higher education and who want jobs regardless of
financial need. This means that jobs may be located and developed
under the JLD Program for FWS and non-FWS eligible students.

Under the JLD Program, your school must locate and develop off-
campus jobs that are suitable to the scheduling and other needs of the
employed student and must, to the maximum extent practicable,
complement and reinforce the educational program or vocational goal
of the student.

JLD jobs may be part-time or full-time, for either a profit or


nonprofit employer.

The JLD Program encourages students to participate in


community service activities. Your school must inform all eligible
students of the opportunity to perform community services and must
develop and make available information about community service
opportunities. The JLD Program uses the same definition of
community services that the FWS Program employs (see chapter 5).
However, the JLD Program does not have a specific minimum
community service requirement, as does the FWS Program.

JLD PROGRAM PARTICIPATION


A school that participates in the FWS Program is also eligible to
participate in the JLD Program. A school that has an executed
Program Participation Agreement (PPA) for the FWS Program may
participate in the JLD Program without any prior contact with the
Department and without any revision to its PPA. Under the PPA, the

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school agrees to administer the JLD Program according to the


appropriate statutory and regulatory provisions.

If the Department terminates or suspends a school’s eligibility to


participate in the FWS Program, that action also applies to the school’s
JLD Program.

STUDENT ELIGIBILITY
Any student employed in a job developed under the JLD Program
must be currently enrolled at the school placing him or her in a job. A
school may place in JLD jobs both students who do not meet FWS
student eligibility criteria and those who do meet those criteria.
However, using JLD funds to find jobs only for FWS students would not
satisfy the program purpose of expanding off-campus jobs for students
who want jobs regardless of financial need.

USE OF FWS ALLOCATION FOR JLD PROGRAM


Maximum Federal Funds for JLD When establishing or expanding a program to locate and develop
Programs Cite off-campus jobs, including community service jobs, a school may use
34 CFR 675.32 up to the lesser of the following two amounts:

• 10% of its FWS allocation and reallocation; or

• $50,000.

USE OF JLD PROGRAM FUNDS


Used of JLD Funds Cite Your school may use federal JLD funds to pay for the cost of
34 CFR 675.35(a)(2) establishing and administering the JLD Program. You may not use JLD
funds to:

• pay students whose jobs were located and developed through


the JLD Program;

• locate and develop jobs at your school or other eligible schools;

• place students upon graduation; and

• displace employees or impair existing service contracts.

A school is expected to generate total student wages exceeding the


total amount of the federal funds spent under JLD.

FEDERAL SHARE LIMITATION


You may use federal FWS funds to pay up to 80% of the allowable
costs (listed below). Your school must provide the remaining 20% of
allowable costs either in cash or in services. This requirement, unlike

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the institutional share requirement for FWS earnings, cannot be Federal and Institutional Shares
waived. Cite
34 CFR 675.33(b)
34 CFR 675.33(c)
The institution’s 20% share may be either (1) 20% of each
allowable cost, or (2) varying percentages of allowable costs, as long as
its total expenditures of institutional funds and/or provision of services
equals at least 20% of the total allowable costs for the JLD Program.

You must maintain records that indicate the amount and sources
of your school’s matching share. Procedures and records
requirements for JLD are the same as those for all campus-based
programs.

ALLOWABLE PROGRAM COSTS


Allowable costs of carrying out the JLD Program include: Allowable Costs Cite
34 CFR 675.33(a)
• staff salaries (and fringe benefits, if they are the same as those
paid to other institutional employees in comparable positions
and are not paid to a student employed through the FWS
Program);

• travel expenses related to JLD activities;

• printing and mailing costs for brochures about the JLD


Program;

• JLD telephone charges, including installation of a separate line


for off-campus employers;

• JLD costs for supplies, equipment, and furniture;

• newspaper or other types of advertising that inform potential


employers of the services JLD offers; and

• JLD workshops for students and employers.

Costs that are not allowable are costs related to purchasing,


constructing, or altering the facilities that house a JLD project. Indirect
administrative costs also are not allowable. One example of an indirect
administrative cost is a portion of the salary of someone who is not
directly involved in the program, such as the JLD director’s supervisor.
Other examples of indirect administrative costs are lighting,
heating, or custodial costs incurred as part of the normal operations
of the facility in which the JLD Program is administered, such as the
financial aid or placement offices.

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STUDENTS AS STAFF IN THE JLD PROGRAM


OFFICE
The prohibition against using JLD funds to locate and develop
jobs at any school does not mean that your school is also prohibited
from employing FWS and non-FWS students as staff in the JLD
Program office. Your school may employ FWS and non-FWS
students as staff in the JLD Program office as long as you do not use
JLD funds to locate and develop these jobs. For example, your
school could use the FWS Program to employ an FWS student as a
staff member in the JLD Program office.

If your school places an FWS student as staff in the JLD Program


office, there are some important points to note. The statute and the
FWS regulations prohibit the use of any funds allocated under the
FWS Program from being used to pay the institutional share of FWS
compensation to its students. Hence, your school may not use
federal JLD funds to pay the institutional share of FWS wages earned
by an FWS student working as staff in the JLD Program office. Intead,
you must use your school’s funds to pay the institutional share of these
wages and, since JLD allowable costs include staff salaries, you may
count those funds in meeting the minimum 20% institutional share
requirement for the JLD Program.

Finally, your school may not include student staff jobs in the
JLD Office on the FISAP in the JLD section for reporting the count
of students and the earnings of students for whom jobs were located
or developed through the JLD Program.

JLD REPORTING ON THE FISAP


If your school participates in the JLD Program during an award
year, you must provide information about its JLD activities on the Fiscal
Operations Report and Application to Participate (FISAP). You must report
the total JLD expenditures, federal expenditures for JLD, institutional
expenditures for JLD, number of students for whom jobs were located
or developed, and total earnings for those students.

MULTI-INSTITUTIONAL JLD PROGRAMS


Multi-Institutional Programs Cite Your school may enter a written agreement with other eligible
34 CFR 675.34 schools for those schools to establish and to operate a JLD Program for
its students. The agreement must designate the administrator of the
program and must specify the terms, conditions, and performance
standards of the program. Each school that is part of the agreement
retains responsibility for properly disbursing and accounting for the
federal funds it contributes under the agreement.

For example, each school must show that its own students have
earned wages that exceed the amount of federal funds the school
contributed to locate and develop those jobs. This fiscal information
must be reported on each school’s FISAP.

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If your school uses federal funds to contract with another school,


suitable performance standards must be part of that contract.
Performance standards should reflect each school’s philosophy,
policies, and goals for the JLD Program. You may not develop
performance standards, conditions, or terms that are inconsistent with
the statute or regulations. In all cases, the performance standards
should be clearly understandable, because they will be included in the
formal written agreement that each party must observe as part of its
responsibility within the particular arrangement.

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